Products spotted in EU stores and online platforms often come with information on how to recycle their packaging. However, the rules on recycling symbols change from Member State to Member State and only some of them require recycling symbols by law.
While currently the EU has no harmonised symbols to affix on labels, this will change soon thanks to the new EU Packaging Waste Regulation.
Rules on recycling symbols change from country to country
Essentially, every country has their own rules about recycling symbols. Some countries such as Italy, France, and Spain impose the use of recycling symbols. In addition, France mandates the use of the Triman logo when giving waste disposal information. Other countries – such as Germany – do not impose the use recycling symbols. Nonetheless, when choosing to display them, Germany allows only the information on packaging that is included in the VerpackG, the German law on packaging.
Interestingly, the Triman logo is subject to two infringement proceedings due to incompatibility with the free movement of goods’ principle.
Harmonisation is coming with the new EU Packaging Regulation
To make it easier for consumers to sort and dispose packaging waste correctly, the European Union is going to introduced a system of harmonised symbols. With the new Packaging Waste Regulation, the EU is addressing the issue of fragmented rules across the Union market.
By August 2028 (or later, depending on when the implementing act is published), packaging placed on the EU market shall be marked with a harmonised label on sorting information by indicating its material composition. In the next years, the European Commission will adopt implementing acts to determine such symbols. To safeguard the Union market and free movement of goods, national requirements should not create obstacles to the market access of packaging compliant with the EU Packaging Regulation.
Notably, the EU Packaging Regulation is tackling many different aspects of packaging, not only the harmonisation of disposal information. Among others, the Regulation sets out provisions on substances, recyclability, compostability, reusability, and packaging minimisation. The Commission should clarify further aspects which might mislead or confuse consumers in future guidelines.
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We can guide you through the EU and national requirements for recycling symbols. You can send your questions here or write us at prodlaw@obelis.net.
References:
EUR-Lex (2025). Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC. Retrieved on 17/03/2025.
Bundesministerium der Justiz (2017). Gesetz über das Inverkehrbringen, die Rücknahme und die hochwertige Verwertung von Verpackungen (VerpackG). Retrieved on 17/03/2025.
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